Lauren Paige Woodard Mitchell v. Adam Stephenson Mitchell
180 So. 3d 810
| Miss. Ct. App. | 2015Background
- Adam and Paige Mitchell married in 2009; Mann born 2011; separation occurred before moving to Meridian; custody litigation began in 2012-2013; chancery court awarded Adam physical custody with Paige visitation; Paige appealed asserting several trial errors; final judgment affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Albright custody factors applicability | Mitchell argues misapplication of Albright to favor Adam | Mitchell contends Albright factors support Adam | Albright applied and supported custody to Adam |
| Limitation of witness testimony | Paige argues trial restrictions harmed her case | Adam contends discretion properly exercised | No abuse of discretion; restrictions justified by disclosure issues |
| Legal custody determination | Paige seeks joint legal custody but argues error in sole custody | Adam argues joint legal custody not feasible given hostility | Chancery properly awarded Adam sole custody; joint custody not warranted |
| Visitation award sufficiency | Paige seeks more or different visitation arrangement | Adam argues current schedule best for Mann given distance | Visitation schedule affirmed as in Mann’s best interest |
Key Cases Cited
- Albright v. Albright, 437 So. 2d 1003 (Miss. 1983) (establishes Albright custody factors)
- O’Briant v. O’Briant, 99 So. 3d 802 (Miss. Ct. App. 2012) (Albright framework review; no manifest error if supported by substantial evidence)
- Hall v. Hall, 134 So. 3d 822 (Miss. Ct. App. 2014) (Albright factor application reviewed for substantial support)
- Smith v. Smith, 97 So. 3d 43 (Miss. 2012) (standard deference to chancery findings on facts; de novo on law)